Information: New Packaging Act January 2019

Information: New Packaging Act January 2019

Europe-wide, the manufacturer of a product must also assume product responsibility for the packaging. We would like to draw your attention to the fact that the new Packaging Act (VerpackG) comes into force on 1 January 2019 and replaces the former Packaging Ordinance (VerpackV). This results in new obligations for manufacturers and distributors, so-called first-time suppliers of B2C packaging.

It is the obligation of the first-originator to include his packaging in an officially approved disposal system and to draw up a declaration of completeness annually on the packaging materials which he places on the market. For the sake of transparency, manufacturers must report this information to a central office as a data report on (dual) system participation. The foundation Central Office Packaging Register takes over in this context u.a. the task of collecting the product managers and making them public in the packaging register LUCID. Manufacturers who have to use packaging on a dual system should register there. You will find a guideline that basically informs you about the duties of product responsibility and the procedure of registration: https://www.verpackungsregister.org/information-orientierung/hilfe-erkla....

For Private Label, it was decided as follows: "If sales packaging filled with goods is placed on the market under a private label of the trade, it is not the bottler but the trading company obliged to participate in a system to ensure the widespread return of the sales packaging and to document this by means of a declaration of completeness to be filed with the Chamber of Commerce and Industry.  ...  "(Source: Press Release of the Federal Administrative Court No. 76/2015 https://www.bverwg.de/pm/2015/76).
Thus with private label products the bottler / manufacturer is not responsible, but the brand owner, who then distributes the product commercially as the first-time marketer. This means that if the products are private labels and the products are not sold under GLUETEC names or brands, GLUETEC will no longer be the first-in-store of the products and their packaging. Thus, GLUETEC is also not responsible for the licensing or billing of the packaging.

We advise you to inform yourself accordingly about your new duties and to look for a partner for dual disposal systems, if you have not already done so. An overview of the recognized dual disposal systems can be found until the end of 2018 on the IHK homepage www.ihk-ve-register.de. From January 2019, the declaration of completeness is no longer to be submitted to the IHK, but to the Central Office.